Analysis of Proposals for Compliance and Enforcement Testing Under the New Part 431; Title 10, Code of Federal Regulations

Under section 431.24 of the DOE's Proposed Rule for compliance with EPCA, the manufacturer would determine the average full-load eeciency of each basic model of electric motor either by testing or by application of an Alternative EEciency Determination Method AEDM. Under section 431.127 of DOE's Proposed Rule for enforcement of EPCA, the DOE would ascertain, through an enforcement sampling plan, the accuracy of information disclosed in the labeling and the marking of the electric motor to indicate its energy eeciency, and whether the motor complies with EPCA standards. During the public comment period, NEMA raised issues concerning the DOE's proposed sampling plans for compliance and enforcement. According to NEMA, the compliance criteria in the Proposed Rule are inconsistent with NEMA Standards Publication MG1-1993, Motors and Generators," and place a high burden on manufacturers. Moreover, NEMA contends that the Proposed Rule would require that electric motors covered by EPCA be engineered to exceed the average full-load eeciency levels prescribed by EPCA. This report evaluates the operating characteristics of the DOE's and NEMA's proposals within the context of EPCA: Compliance with the energy eeciency levels for motors prescribed by section 342b1 of EPCA appears to be satissed when the true mean full-load eeciency of the population of each basic model of electric motor equals or exceeds the applicable nominal full-load eeciency.